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UPI Merchants Face Reclassification Risk Despite ₹1 Lakh Monthly Threshold

Small UPI merchants processing up to ₹1 lakh monthly in eligible QR payments currently enjoy exemption from merchant discount rate charges, but repeated threshold breaches risk triggering reclassification to costlier merchant-to-merchant payment categories.

LSN India · 20 September 2026

UPI Merchants Face Reclassification Risk Despite ₹1 Lakh Monthly Threshold

India's UPI ecosystem has introduced a ₹1 lakh monthly ceiling to determine which small merchants remain exempt from merchant discount rate (MDR) levies under the new regulatory framework. This threshold provides relief to a vast segment of India's informal and semi-formal retail sector that depends on digital payments through QR codes.

However, the exemption comes with a critical caveat: merchants who consistently exceed the ₹1 lakh limit face potential reclassification into higher MDR regimes, substantially increasing their transaction costs. This mechanism is designed to prevent merchants from gaming the system by splitting transactions or deliberately remaining under the threshold to avoid MDR charges.

The distinction between eligible and ineligible UPI payments also matters significantly. Only payments that fall within specified eligible categories count toward the ₹1 lakh limit, meaning transactions outside these parameters do not contribute to a merchant's monthly tally. This creates complexity for many small business operators attempting to understand their exact liability.

Regulatory authorities have emphasized that the threshold serves as a policy tool to support genuine micro-merchants while ensuring that growing businesses contribute proportionately to payment infrastructure costs. Merchants approaching or regularly exceeding the ₹1 lakh mark are advised to maintain detailed transaction records and understand the reclassification criteria applicable in their state or region.

The implementation of this tiered approach reflects ongoing efforts to balance financial inclusion objectives with sustainable payment ecosystem economics, as India continues expanding digital transaction adoption across rural and urban merchant networks.